Ethics & Compliance Investigations
All reported concerns to the VCU Helpline or direct to the ICO, or notice given to ICO staff, related to university activities and misconduct or wrongdoing are taken seriously. We appreciate very much the courage it takes to make a report about something you have experienced in your work environment, especially when reporting outside of your operational unit.
Did you know that only 1 in 20 individuals are motivated to report outside a company for financial reward? And, that the average number of times an internal whistleblower reports a concern is 3 times — usually prompted by wanting to improve the process or trying to get something right? We did!
And we know your trust is delicate and it is a privilege to be able to help anyone who believes wrongdoing has happened. That's why conducting a fair and transparent process that addresses reported concerns is critical. We are happy to answer any questions our university community members may have, any time. You can reach us at ucompliance@vcu.edu.
Here's a little more detail about the process:
Every concern is first assessed for merit. Meaning, the information shared is initially deemed credible and relates to university activities and personnel. Once a concern (allegation) is deemed to have merit, a preliminary vetting process is undertaken to determine what the issues are, where particular expertise in the university exists to further address or investigate, whether independence from routine management lines is needed, and provide assurances that units involved in addressing concerns are free from conflicts.
Most of the time, this process involves other departments at the university with the ICO maintaining a line of sight over the inquiry and investigation processes as they proceed. The preliminary vetting process occurs before a commitment to a formal investigation by the ICO is made.
Reporters (the individual coming forward with a good faith report of actual or suspected misconduct) will be communicated with as to what office will be addressing the concern and should expect to be informed periodically throughout the process. If you feel this is not happening, please let us know - we will look into it and follow-up with you. A notice messaging the close of investigation will be provided to reporting parties, and any participating witness who requests one.
Internal workplace investigations determine whether misconduct exists. They use a standard of proof called a preponderance of the evidence, incorporate credibility assessments of information and individuals and provide subjects of allegations notice and an opportunity to respond.
Misconduct is defined as failing to meeting university expectations defined as compliance with laws, regulations or universitywide polices and procedures. This includes the most commonly violated policy, Expectations of Ethical Conduct.
Corrective action aimed at preventing recurrence must be taken when misconduct exists. This responsibility and decision belongs to management or senior leadership in the subject's chain of command. Corrective, remedial or disciplinary actions taken are the decisions of management, based on established facts that support an inquiry or investigation's findings. At the conclusion of every investigation, a final determination is reached and conveyed to the appropriate senior leadership member(s).
VCU's commitment to non-retaliation
By asking a question, raising a concern in good-faith or participating in a workplace investigation, you are following the Code of Conduct and doing the right thing. Retaliation (or threat of retaliation) is not tolerated.
Retaliation is any action or words taken against an employee who raised a question or concern in good-faith or participated in an investigation that would discourage a reasonable person from speaking up or sharing information about a concern. Examples include questioning employees about their participation in an investigation, unexplained and unwarranted changes in work assignments or job responsibilities, unjustified negative evaluations/references, demotion or dismissal, and increased scrutiny/oversight of work that is not related justifiably to performance management. Managers should be especially mindful of taking actions that may be perceived as retaliation. To learn more, please review the universitywide Duty to Report and Protection from Retaliation policy.
Crimes are reported to VCU Police and the Commonwealth’s Attorney Office.
Questions about this process may be directed to the University Chief Ethics & Compliance Officer at 828-2336.